Abstract
The last decade witnessed the European Union taking tentative steps towards the likely abolition of each member state contract law, and its substitution with a single European Contract Law Code. Indeed, the European Union usually solves inconsistencies in contract law by legislating them in a very defined and closed area. For example, in 1977, the EU had implemented the Unfair Consumer Terms Act after analyzing that there were a growing number of consumer complaints from cross-member states. It did the same while legislating on commercial agents and on late payments in commercial transactions.
Nonetheless, this legislation aims at very specific points and does not interfere with each member state's contract law framework, which still causes conflict of law. It also impedes the great objective of the European Union construction since 1957 and the Rome Treaty, which is reaching the single market implementation.
